The California Transparency in Supply Chains Act of 2010

Last Updated: December 12, 2011

The California Transparency in Supply Chains Act of 2010 requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. At LeapFrog, we are committed to:

a standard of excellence in every aspect of our business and in every corner of the world;

ethical and responsible conduct in all of our operations;

respect for the rights of all individuals; and

respect for the environment.

As part of this commitment, LeapFrog maintains and enforces written policies and procedures that strictly prohibit the use of slavery or human trafficking in its direct supply chain. We continue to update these policies and procedures as needed to ensure that we have appropriate safeguards against any mistreatment of persons involved in our direct supply chain. Currently, LeapFrog’s efforts to eradicate slavery and human trafficking in our supply chain include the following:

Supply Chain Verification

LeapFrog is an active member of The International Council of Toy Industries (ICTI), an association committed on behalf of its member companies to the operation of toy factories in a lawful, safe, and healthful manner. ICTI upholds the principles that no underage, forced, or prison labor should be employed; that no one is denied a job because of gender, ethnic origin, religion, affiliation or association, and that factories comply with laws protecting the environment. LeapFrog uses only manufacturers that have been certified by ICTI as compliant with its ICTI’s Code of Business Practices.

Supplier Audits

Prior to engaging a contract manufacturer, we examine every aspect of its business, including employee welfare and social responsibility. Having a “Seal of Compliance” from ICTI CARE (Caring, Awareness, Responsible, Ethical) Process audit is one of the key aspects being considered during supplier selection as it reflects supplier compliance with our standards for, among other things, trafficking and slavery in supply chains. “ICTI CARE Process” is a toy industry ethical manufacturing program aimed at ensuring safe and humane workplace environments for toy factory workers worldwide. These unannounced audits are conducted annually by an independent certified third party auditing agency.

Supplier Certification

We require all of our contract manufacturers to sign our Materials Sourcing and Manufacturing Agreement (MSMA) which prohibits the incorporation of materials in our product that do not comply with the laws regarding slavery and human trafficking in the country in which they are doing business. The MSMA also requires our contract manufacturers to abide by LeapFrog’s Supplier Code of Conduct which prohibits the use of forced or involuntary labor and requires adherence to all applicable laws and regulations.

Internal Accountability Standards

Leapfrog’s Code of Business Conduct and Ethics requires all employees to comply with all applicable laws, including those regarding slavery and trafficking. Employees who do not comply with the law or who violate the Code are subject to disciplinary action which includes termination of employment.

Training

LeapFrog trains employees responsible for supply chain management on certification of our suppliers, including compliance with our Supplier Code of Conduct, which prohibits slavery and human trafficking. All employees receive training regarding our Code of Business Conduct and Ethics, which includes compliance with all applicable laws.